Select Committee on Welsh Affairs Written Evidence

Written Evidence from Airtricity


  The Welsh Affairs Committee has invited organisations and members of the public to submit memoranda setting out their views on this inquiry. This submission concentrates on the framework required to enhance the development of onshore wind in Wales, and suggests changes that could be implemented to promote the timely development and construction of onshore wind. It is structured as follows:

    —    Section 2 briefly discusses the requirements for the continued expansion of onshore wind.

    —    Section 3 sets out views on the policy issues affecting wind resource development in Wales.

    —    Section 4 examines the viability of the current targets.

    —    Section 5 provides a summary of the paper.


  The Energy White Paper[16] of February 2003, set out a vision in which renewables and energy efficiency would play a key role in UK energy policy and secure the gap left by the decline of current nuclear and coal generating capacity. It is against this background that the renewables sector in general, and the wind industry in particular, has being evaluating its investment plans and project development strategies.

  The stability of the current renewables framework has enabled onshore wind to make a major contribution towards government targets, benefit from technology and cost improvements, and develop an overall infrastructure to support continued development.

  Uncertainty regarding the Government's intentions towards new nuclear capacity, triggered by the recently announced Energy Review, has the potential to damage further investment in renewables and energy efficiency. Equally, potential changes to the current government and regulatory frameworks to facilitate new nuclear build need to be fully thought through, with regard to both their direct and indirect impact on the renewables sector. Onshore wind is a success story for the UK and has delivered significant benefits. Given the appropriate framework, it can deliver much more. Although not a completely mature sector, onshore wind experience is such that the government is well informed with regard to the likely path of cost curves for the industry, as it develops further. A potential key concern for current and future development will be the coordination, efficiency and timeliness of the overall planning process. Consideration should be given to reviewing the framework applicable to wind project planning, such that each development only has to address truly significant, specific issues. If planning develops on a case-by-case basis, where no "case law" is laid down, and all issues are reopened each time, it is highly likely that the pace of onshore wind resource development will slow significantly.


  In supporting the Government's energy policy objectives, it is important that there are no inconsistencies between the frameworks for UK and regional government. The challenges of climate change, and the UK government's response to these, need to be met in a coordinated and consistent manner, in order to facilitate continued confidence within the renewables industry. The strategy to meet UK objectives is best developed within a UK wide framework.

  A key UK wide issue is that of greater certainty with respect to the renewables market post 2015-16. This could be achieved either by increasing the Renewables Obligation post 2015 (to say 20.4% by 2020-21) or by guaranteeing a margin post 2015-16 between the renewables obligation and renewables supplied to avoid the cliff-edge.

  With regard to Welsh Energy issues, clarity is required as to the extent to which responsibility for policy development to support those strategies rests with Westminster and the devolved Welsh Assembly. The situation is complicated further when the final and most important step, that of implementation, is considered. Where responsibilities for implementation between different Agencies, Authorities and bodies are unclear or potentially in conflict, the process of development is compromised.

  Energy Policy in Wales largely rests upon the findings of the Welsh Assembly Government Economic Development Committee Review of Energy Policy in Wales: Part 1 Renewable Energy (2003). The six key recommendations of the review frame the relevant issues concerning the division of powers regarding energy, renewable energy targets, and the requirement for specific policy initiatives from the Assembly.

  With regard to renewable energy and facilitating the targets set for 2010, the most significant devolved power has been planning policy. The relevant policy in this area is "Technical Advice Note 8—Planning Policy Guidance for Renewable Energy".

  Onshore wind will be the key component in meeting the 2010 targets. The pace of wind farm development will largely depend on the efficiency of the planning policy, and its implementation, in facilitating development.

  In 2001 studies were carried out to quantify the Welsh Renewable Energy Resource in order to inform the Welsh Assembly Economic Development Committee (EDC) Review of Energy Policy in Wales (Jan 2003). The report estimated a long term potential, taking account of technical, economic and environmental constraints, in the region of almost 12TWh electricity and 5TWh heat.

  The original assumption by the Assembly was based on an approximately equal split between onshore wind, biomass and "other" renewable electricity technologies. This was subsequently revised, giving onshore wind a greater role, following further investigation into the economics of biomass electricity production.

  These assessments underpinned a number of EDC recommendations including a proposal (Recommendation 2) to adopt targets for Welsh renewable energy generation for 2010 and 2020. Crucially, the Recommendation contained the following statement: "In order to promote these targets the National Assembly should seek information from all Local Authorities on the contributions that they consider could be made to meeting such targets from within their areas."

  The Welsh Assembly subsequently chose to adopt a target of 4TWh of electrical production by 2010, together with an aspiration of 7TWh by 2020. This was at the high end of the range of potential targets specified within the EDC report.

  Within the framework of devolved powers relating to energy policy, the National Assembly were constrained in the choice of mechanisms within which to pursue the target. Planning policy provided one mechanism, and this was recognized by Recommendation 5 of the EDC:

    "The National Assembly should:

      (a)  as a matter of urgency, seek ways to clarify and streamline the planning process for renewable energy developments;

      (b)  seek an extension of its powers with regard to the approval of power generation facilities;

      (c)  find mechanisms whereby renewables developments can provide immediate and tangible benefits to the local communities in which they are located."

3.1  Technical Advice Note 8 (TAN 8)

  Whilst TAN 8 includes a target of 200MW installed capacity for offshore wind and other renewable technologies, it is primarily focused on the delivery of onshore wind capacity. The TAN specifies seven Strategic Search Areas (SSAs) within Wales. These are the preferred locations for large scale wind energy developments. A key element in the development of these SSAs is the involvement of the Forestry Commission, who manage approximately 56% of the land area within them.

  The approximate capacity of each area has been estimated, and on this basis a target figure of 800MW of onshore wind has been established. The effect of the policy and definition of the SSAs leads to a de facto maximum area available for large wind farms, which face less likelihood of success outside the SSAs. Local Planning Authorities are tasked with further "refining" the SSAs within their areas.

  This approach differs from that established for England through PPS22, which uses a criteria based, rather than geographic approach. It has focused development effort on the SSAs, in the expectation that viable projects will be facilitated.


  The target for 2010 is 4TWh per annum of electrical energy. Assuming a capacity factor of 30%, then 800MW of installed wind capacity would produce some 2.1 TWh of energy. The assumed 200MW of other renewables is unlikely to be operating at 100% load factor and thus the target of 4TWh per annum appears unachievable.

  Further, the policy itself, by constraining major wind development to the SSAs, risks undershooting on the level of installed wind capacity for 2010.

  Using a criteria based approach, similar to England, would have allowed developers the maximum freedom to seek out and develop suitable sites.

  The seven SSAs have their own specific constraints which will hinder large scale development. In particular, extensive forestry, site access and slope gradient appear to render the current Nant y Moch area impractical for large scale wind farm development. These and other constraints such as the restrictions imposed by NATS radar have not been fully considered in assessing the potential of the SSAs and are likely to constrain the level of achievable capacity within the SSAs to below the 2010 target.

  Consideration should be given to extensions to the seven SSAs. Additional designated areas would also significantly ease development pressure and increase the likelihood of meeting the 2010 target. This might be achieved by the use of "conditional strategic areas" which would be suitable for major wind farm development where specific conditions can be satisfied. This would ensure that significant areas for wind farm development are not being excluded due to the location of sometimes small designated sites or areas. Technical solutions exist to many of the perceived constraints such as telecommunication masts and re-broadcast links. Similarly, with regard to SSSIs, nature and bird reserves the constraint is site specific and depends on whether the renewable energy development would compromise the purpose of designation. A specific example is that of Area D, Nant y Moch, which currently excludes a potentially suitable area between its South Western boundary and an existing wind farm development.

  The main technical barrier to reaching the TAN 8 capacity targets by 2010 will be grid availability and capacity. The SSAs were selected without proper consideration of the necessary level of Grid reinforcement (and the time to reinforce) that would be required to connect the target MW capacity. Upgrading the grid infrastructure is likely to impose a time lag of between five and eight years in five SSA areas (Brechfa Forest, Nant y Moch, Llandinam, Carno, Clocaenog Forest).

  Efforts should therefore be made to reduce the lead in times for additional 132kV lines, to support the 800MW target. Failure to strengthen the grid in a timely manner will render major developments unviable, the strategic search area approach invalid and the materially compromise the achievability of the 800MW onshore target.

  Wind farm development within mature forestry carries many additional complications and is an immature area with regard to available data and experience. Due to the additional risks and complexities, heavily forested areas have not been a primary choice for wind project developers. Over 50% of the SSA area is within forestry, and whilst the precise impact is unquantified, the likelihood is that the higher turbulence in forested developments will result in additional costs and lower outputs per installed MW, compared with non-forested sites.

4.1  Process and co-ordination issues

  It was noted above that the majority of the SSAs fall within Forestry Commission responsibility. Despite this, consultation and coordination between the Assembly and the Commission has not been as effective as it might have been, with the Forestry Commission only being included in the process at a relatively late stage. This has resulted in resourcing problems at the Commission, who are dealing with the practicalities of the incorporation of numerous major developments within existing long term forestry planning processes.

  The timetable set out by the Assembly has been subject to considerable delay. Without a clear deadline to deliver, the process may be further impeded by any slippage by local planning authorities, both in terms of "refining" SSA areas and in dealing with the large number of applications linked to SSAs. The impact of this process shortfall can lead to planning decisions being delayed for more than two years.


  5.1  In supporting the achievement of the Government's energy policy objectives, it is important that there are no inconsistencies between the frameworks for UK and regional government.

  5.2  In order to promote a long term approach in line with UK Government energy policy, firm targets for renewable energy in Wales for 2015 and 2020 are required, in addition to those for 2010.

  5.3  The use of a strategic geographic approach, characterized by TAN 8, rather than a broader criteria based approach, has implications for the development of renewable energy in Wales. The adoption of seven SSAs for large scale onshore wind projects has the potential to unnecessarily constrain renewable development and risks achievement of the 2010 targets.

  5.4  Given the experience of implementation so far, urgent action is needed to meet the 2010 target and 2020 aspiration—this applies not only to construction and commissioning but to planning processes and consents, grid capacity and connections.

  5.5  The 2010 target is unlikely to be met solely by developments within the existing seven strategic search areas (SSAs). Stakeholders need to work with the Assembly to identify alternative and additional options to ensure the targets are met.

  5.6  Within the current framework, there is a need to ensure consistency between the various stakeholders at national, regional and local levels, to ensure that viable projects are facilitated in a timely manner.

  5.7  Local Planning Authorities need to be firmly aligned with the objectives and policies of the Assembly, in order to facilitate progress. Clear, criteria based local planning policy should guide wind turbine location at a local level, particularly outside the strategic search areas. Failure to encourage appropriate wind farm developments of all sizes in wider areas than the SSAs heightens the significant risk of missing the 800MW onshore wind target.

  5.8  A key requirement for all major renewable electrical energy projects is the availability of sufficient Grid connection and transmission capacity, in a timely manner. The proper integration and coordination of grid reinforcement in Wales is an essential part of overall Energy Policy and must be addressed.

2 December 2005

16   Energy White Paper: Our energy future-creating a low carbon economy, DTI, February 2003. Back

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